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Where the clinical benefit of a service, when provided via telehealth, is clearly analogous to the clinical benefit of the service when provided in person, CMS will assign the code permanent status on the Medicare Telehealth Services List, even if the code's service elements do not map to the service elements of a service that already has permanent status

To recognize the resource costs associated with furnishing APCM services to Medicare beneficiaries, we are proposing to establish and pay for three new G-codes that describe a set of care management services and CTBS furnished under a broader application of advanced primary care

We also included an exception in this sixth criterion to allow us to use an alternative approach for Advanced APMs that do not base attribution on E/M services, and thus for which attributed beneficiaries are not a subset of the attribution-eligible beneficiary population based on the requirement to have at least one claim for an E/M service